|Received:||7/2/2006 6:45:11 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I applaud your effort to establish comprehensive accountability and transparency for those offering business opportunities in the area of multi-level marketing. As a Quixtar IBO, I have always adhered strictly to Quixtar’s disclosure guidelines, and have not found it burdensome to be honest and aboveboard with regard to what the business is about. I fear that some of the provisions in the proposed law will place an undue burden on those of us honestly offering an opportunity to others: specifically, the 7-day waiting period, the requirement for references, the disclosure of past litigation (in today’s litigious society, frivolous lawsuits against high-profile companies are the rule, not the exception), and the disclosure of financial records. While these are quite reasonable standards to apply in many other industries, such as timeshares and franchises of publicly held companies, they would be onerous to those of us in this industry. Most of us operate as sole proprietorships working from home; our time is already limited, as we hold down jobs during the day while bringing our businesses to maturity. The paperwork burden this would add to the process would severely hamper our efforts. And the financial disclosure provisions would, I believe, severely strain our right to privacy. Quixtar (and, before it, Amway) has always had a stellar reputation for honest dealing and full disclosure in prospecting. This is due to two things: the personal integrity of the families owning the corporation, and the Federal rules applied to Amway (and, by extension, to Quixtar) back in the 1970s. I believe the best way to bring across-the-board integrity to prospecting in our industry is to use, as much as possible, the Federal rules Quixtar already adheres to for the template for these new regulations. Thank you for the opportunity to be heard and for your efforts to bring accountability to the entire industry.